EPA Updates Ozone Depleting Substances Regulation

In November of 2016, EPA finalized changes to Section 608 of their Refrigerant Management Regulations. These changes will affect professionals and facilities that utilize refrigerants. These changes took effect on January 1st, 2017 and currently remain in place. Unlike many other regulations, these are NOT likely to be canceled or delayed because these specific changes took effect before January 20th. These changes are summarized below:

• Starting January 1, 2018, uncertified technicians must pass a certification exam updated to reflect these new rules and offered by an approved certification program in order to maintain, service, repair or dispose of appliances containing ODSs or substitute refrigerants. Technicians must maintain a copy of their certificates at their workplace for at least three years after they cease technician work.

• The requirements of the Refrigerant Management Program have been extended to also cover substitute refrigerants, such as HFCs. Note that EPA has previously exempted some substitutes from the Section 608 venting prohibition through previous rules. Such substitutes are also exempt from the requirements of this rule.

• New recordkeeping requirements have been added to EPA’s requirements for owner/operators:

o Documentation of the full charge of appliances.

o Records of when maintenance is performed, when refrigerant is added or removed, when leak inspections are conducted, and when verification tests are conducted.

o Automatic leak detection systems users must document that the system is installed and calibrated annually and record leaks identified by the monitoring system, including the time and location of the leak.

o Retrofit/retirement plans

o Requests submitted to EPA to extend repair/retrofit deadlines.

o Documentation of when a system was temporarily taken out of service to suspend a repair deadline, if applicable. Corresponding documentation must be maintained when refrigerant is added back into the appliance and it is brought back on-line.

o Records to demonstrate a seasonal variance.

o Reports for appliances identified as leaking 125% or more of their full charge within a calendar year.

• The new rules lower the leak rate thresholds that trigger the need to conduct inspections and change the requirements for resultant reports and repair. These new thresholds are applicable to equipment containing 50 or more pounds of refrigerant.